1. Policy framework statement
This Policy sets the framework for how Silver Chain Group Limited ACN 077 082 725 and its related companies Royal District Nursing Service of SA Limited ACN 151 858 025, Silver Chain – Victoria Limited ACN 649 647 914 and Silverchain Foundation Ltd ACN 077 086 670 (collectively, Silverchain, we, us or our) manages the Personal Information of its clients, service providers, personnel and other people and organisations that it has a relationship with.
This Policy applies to individuals only to the extent that the collection and handling of Personal Information by Silverchain is subject to the Privacy Act 1988 (Cth) (Privacy Act).
Silverchain is committed to the protection of privacy and to the compliant collection, storage, use and disclosure of Personal Information.
2. Background
Where the collection or handling of Personal Information by Silverchain is subject to the Privacy Act, we must comply with the requirements of that Act. The Privacy Act regulates the manner in which Personal Information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.
Personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Special provisions apply to the collection of Personal Information which is sensitive information. This includes health information and information about a person's race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical belief, sexual preferences and criminal history.
The collection or handling of Personal Information by Silverchain may also be subject to other legislative requirements depending on the particular circumstances (for example, State health records legislation may apply).
In this Policy, all references to Personal Information include personal and sensitive information unless indicated otherwise.
3. Collection of Personal Information
To enable Silverchain to deliver services to its clients and to otherwise operate its business, Silverchain collects Personal Information from those clients, personnel, suppliers and other parties.
From clients we may collect Personal Information including a clients’ name, date of birth, phone number, address, email address, financial and banking information, government identifiers (such as Medicare number or Department of Veterans Affairs number), photos and sensitive information such as health information, ethnicity (including Aboriginal and Torres Strait Islander status), religion and criminal record.
From employees, contractors, volunteers and job applicants we may collect Personal Information including name, address, phone number, email address, financial and banking information, residency and visa details, information about the personnel's skills, qualifications, experience and references, government identifiers (such as drivers’ licence number) and sensitive information such as health information and results of a national police check.
From others such as service providers and sub-contractors we may collect Personal Information including name, address, phone number, email address and financial and banking information.
Silverchain may collect this information from individuals directly, but in some cases, may collect it from a third party such as a referring doctor, a family member who we have authority to contact or referring organisations or government agencies (such as through the Federal Government My Aged Care Portal). Depending on the nature of the individual's interaction with Silverchain, we may collect Personal Information in a number of ways including in person when the individual receives care and services from Silverchain and through Silverchain's website, application forms, correspondence (written and verbal) and surveys.
If an individual does not provide Personal Information requested of the individual to Silverchain, we may be unable to provide the individual with the care and services requested of Silverchain or otherwise work or transact with the individual.
4. Purposes of collection, storage, use and disclosure of Personal Information
Silverchain may collect, hold, use and disclose Personal Information for a range of purposes, including:
a. to provide care and services to clients;
b. to manage its relationship with clients, staff, service providers and sub-contractors;
c. to obtain and manage government funding for its services;
d. to comply with our legal and regulatory obligations;
e. to review, develop, monitor, evaluate, benchmark and improve our services, including to undertake quality improvement reviews and surveys;
f. to recruit, train and educate staff employed or engaged by Silverchain;
g. with consent, to sell and promote its brand and services;
h. with consent, to undertake fundraising activities;
i. to manage and respond to complaints;
j. to process payments and billing for our services; and
k. for other purposes required or authorised by or under law, including purposes for which individuals have provided express or implied consent.
Silverchain's range of services and functions and activities may change from time to time.
5. Disclosure of Personal Information
Silverchain may disclose Personal Information to other persons and organisations, including to:
a. a client’s treating medical practitioner, allied health professional, pharmacist or others involved in the client’s care;
b. medical centres and hospitals attended by a client;
c. individuals employed or engaged by Silverchain who may assist in providing care and services to Silverchain’s clients;
d. a client’s representative, family member or substitute decision maker;
e. government departments and agencies, or bodies or functions administered by government departments and agencies;
f. our related entities;
g. other persons or organisations engaged by Silverchain to assist us in carrying out the above activities such as data storage providers, information technology support providers, insurers and professional advisors. Some of our service providers to which we may disclose Personal Information may be located overseas. A list of the countries in which these service providers are located is available on Silverchain’s website here Disclosure of Personal Information; and
h. parties involved in a prospective or actual transfer of Silverchain's assets or business.
6. Marketing
If an individual has consented to us doing so, Silverchain may use that individual’s Personal Information to contact them in relation to services and products provided by Silverchain that may be of interest to the individual, or services and programs from third parties that may be of interest to that individual.
Individuals may withdraw their consent to receiving marketing information by contacting the Customer Contact Centre on 9242 0242 or the Privacy Officer on 9242 0242 or by emailing privacy@silverchain.org.au.
If you choose not to receive marketing materials from Silverchain, you may still receive service related communications from us.
7. Research and de-identified information
If Silverchain wishes to use Personal Information for research purposes, the information will be de-identified unless you have given your express consent for us to use identifiable information or where an ethics committee has given approval otherwise.
We may also use de-identified information for quality improvement and benchmarking purposes. We may also disclose de-identified information to third parties (such as research partners) for the same purposes.
8. Security of Personal Information
Silverchain generally stores Personal Information in hard copy at its premises and electronically, as well as through third parties who provide services to Silverchain.
To the extent required by the Privacy Act, Silverchain takes reasonable steps to:
- ensure the Personal Information that Silverchain collects, holds, uses and discloses is accurate, complete and up to date; and
- protect the Personal Information that Silverchain holds from misuse, interference and loss and from unauthorised access, modification or disclosure.
Silverchain trains its staff on privacy and security of Personal Information and has policies in place for staff to follow.
Some of our service providers to which we may disclose Personal Information may be located overseas. A list of the countries in which these service providers are located is available on Silverchain’s website here Disclosure of Personal Information.
9. Questions, access and complaints
Silverchain’s Privacy Officer can be contacted with questions about this Policy and about privacy related issues.
Privacy Officer
Silverchain
6 Sundercombe Street
Osborne Park WA 6017
Phone (08) 9242 0242
privacy@silverchain.org.au
Individuals can request access to their Personal Information, change their privacy preferences or correct their Personal Information by sending an email to requestsinformation@silverchain.org.au. Requests for access to, or correction of, Personal Information must be in writing and you must provide proof of your identity.
Silverchain will use its best endeavours to provide individuals with the information requested within 30 days of their request.
In some circumstances and in accordance with the Privacy Act, Silverchain may not permit individuals access to Personal Information, or may refuse to correct Personal Information, in which case we will provide the reasons for our decision, in writing.
If an individual has a complaint about how we have collected, used, stored or disclosed your Personal Information, you may make a complaint by contacting the Privacy Officer on the details above.
We will endeavour to resolve any complaint within a reasonable time frame which will usually not be longer than 30 days. However, if the matter is complex, resolution of the complaint may take longer.
If an individual is not satisfied with Silverchain’s response to a complaint, individuals are entitled to make a complaint to the Office of the Australian Information Commissioner who can be contacted by telephone on 1300 363 992 or via their website at www.oaic.gov.au.
10. Effective date
This Privacy Policy is effective from March 2024.